Transfer pricing comparables and adjustments: Tribunal revisits loss-maker status, segmental comparability, working capital relief, and risk allocatio...
Business expenditure disallowance failed where commission, related-party salary and promotion payments were supported by records and inquiry was inade...
The Tribunal held that the limitation challenge could be decided despite pendency before the Supreme Court because the assessees relied on an unstayed precedent. Reading sections 144C and 153 together, it rejected the Revenue's contention that limitation for a final assessment order under section 144C(13) must be tested only under section 144C. Applying the Roca Bathroom Products line of reasoning, it found the impugned final assessment orders for the relevant assessment years were passed beyond the permissible period and therefore barred by limitation. The orders were quashed, and the remaining grounds were left open.
The Tribunal held that the limitation challenge could be decided despite pendency before the Supreme Court because the assessees relied on an unstayed precedent. Reading sections 144C and 153 together, it rejected the Revenue's contention that limitation for a final assessment order under section 144C(13) must be tested only under section 144C. Applying the Roca Bathroom Products line of reasoning, it found the impugned final assessment orders for the relevant assessment years were passed beyond the permissible period and therefore barred by limitation. The orders were quashed, and the remaining grounds were left open.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4801
Join Channel
TaxTMI 
